IHTM14151 | Lifetime transfers: schemes to exploit annual exemption: introduction
From HM Revenue & Customs · Inheritance Tax Manual
Some transferors make a series of transactions designed to exploit the annual exemption. These fall into two broad types of scheme:
transfer of the property by way of sale (), but with the sale price unpaid and treated as a loan by the transferor which is then written off against the annual exemption, and
annual transfers of portions of a property () - the portions being equal to the annual exemptions.